Last year, EGARA called amongst her members for complaints about the implementation of the ELV Directive in member states. Complaints could be divided in complaints about (de)registration and parts data for reuse of spare-parts.
In November last year, EGARA joined the Fitness Check of the ELV Directive. During this meeting it became obvious that the EC still values old principles like the 5-step waste hierarchy in which Reuse is at the top of all kinds of recycling.
The ELV Directive (ELV Directive 2000/53/EC) is very clear about reuse of parts. The Directive even states that member states should make producers provide data for reuse of parts. Not only the ELV Directive is clear about this information, also the Euro 5/6 Regulation (Euro 5/6 715/2007) is clear: All that ask for parts info should have this info for reasonable costs.
Producers promote the idea of a zero costs model in which the positive value of the vehicle should cover the costs of ELV recycling. In their opinion any funded recycling system is reserving money that should be spend on cars, not on recycling/recyclers. This vision would be true if dismantlers were enabled to actually have acces to every remaining value in an ELV, meaning we should be albe to sell any part that is still functioning and for which the market demands.
Sadly enough, the opposite is true. Producers only give some info about safety and materials in IDIS, but no parts info is provided to dismantlers. Data providers even state they are only allowed to give info to the new sales and the remanufacturing industry, but the dismantling industry is not on the list. In some countries the producers even put in their contracts for taking part in the recycling system the prohibition of selling certain parts. This conflicts with both the Directive as the Euro 5/6 Regulation.
The need for good information is growing. Parts look alike, but sometimes are not the same and sometimes are, but used in a range of different vehicles. Also sometimes there’s a chaos of partsnumbers for the same part. Some have more than 50 different numbers and the part itself didn’t change one bit! Apart from that, parts contain more and more electronics integrated in them, all requiring specific procedures and software to remove them and have them functioning in another vehicle.
EGARA has started to inform the EC about this situation again. It’s probably going to take some time and maybe some strong words, but if the EC wasn’t planning on reuse, they might as well have left it out of the Directive and regulations as we cannot live from windowdressing. And we are willing to pay a reasonable fee, just like any other that receives parts information. The EC as well as the producers need to take their responsibility and do as they say, not just say things. We invested seriously in our legal status, now facilitate us to do our job properly.